If your company qualifies as large under UK law, SECR reporting is no longer optional. It sits inside your annual accounts and goes to Companies House every year. We work with organisations that find SECR straightforward to deliver once the data foundations are in place, and others that scramble in the final weeks because nobody owns it. This guide explains what SECR reporting requires, who has to do it, and how to avoid the issues that catch most finance and sustainability teams out.
What SECR Reporting Actually Requires
The Streamlined Energy and Carbon Reporting (SECR) framework came into force on 1 April 2019. It applies to quoted companies, large unquoted companies, and large limited liability partnerships. “Large” means meeting two of three thresholds: 250 or more employees, turnover of £36 million or more, or a balance sheet total of £18 million or more.
Qualifying organisations must include the following in their annual report:
- Total UK energy use (electricity, gas and transport fuels) in kWh
- Scope 1 and Scope 2 greenhouse gas emissions in tonnes CO2e
- At least one intensity ratio, for example tonnes CO2e per £million turnover
- A narrative description of the energy efficiency actions taken in the year
- The methodology used for the calculations
- Prior-year comparison figures
Scope 3 emissions are voluntary under SECR but are increasingly expected by investors and customers. Most companies disclose at least business travel and employee commuting.
Companies whose UK energy use is below 40 MWh in the reporting year may claim a low-energy exemption, but they still have to state this explicitly in the directors’ report.
Who Must Report and When
Quoted companies have the broadest obligation: global energy and emissions, not just UK. Large unquoted companies and LLPs report on UK energy use only.
SECR reporting must be filed within your annual accounts. For most companies that means within nine months of the financial year end for private companies, and six months for public ones. Late filing brings Companies House penalties from £150 to £7,500 depending on company type and delay. The Financial Reporting Council can also impose civil penalties of up to £50,000 for inadequate disclosure.
The practical implication is that SECR data collection has to start well before year-end, not after it. Teams that wait until accounts are being drafted invariably miss data, rely on estimates, and produce numbers that do not stand up to scrutiny.
The Issues That Catch Companies Out
After several years of supporting SECR submissions across sectors, the same problems come up year after year.
Boundary confusion. Group structures, joint ventures, leased properties and landlord-tenant arrangements are the biggest source of error. If you cannot say clearly which sites are in scope and why, your data is at risk.
Inconsistent fuel data. Transport fuels are routinely under-reported, particularly grey fleet mileage and own-fleet diesel. Many companies pull data from expense systems that were never designed for emissions reporting.
Manual spreadsheets. Hand-keying utility data from PDF bills is slow and error-prone. By the time SECR is signed off, the workings are often impossible to audit.
Conversion factor changes. DEFRA updates its emission factors every June. If you use last year’s factors, your figures will not match the prior-year restated baseline most reports require.
No narrative. SECR demands a description of energy efficiency actions. Companies that focus only on the numbers often miss this, and FRC reviewers flag it.
How to Get SECR Reporting Right
Three things separate clean SECR submissions from painful ones.
First, set up a monthly data routine. Pull utility and fuel data on a fixed schedule across the year rather than in a year-end sprint. This catches missing meters and supplier issues early, while they are still fixable.
Second, document your boundary. Write down which entities are in, which are out, and why. Use the same approach as your financial consolidation where you can, because auditors and investors will compare them.
Third, plan the narrative early. The energy efficiency actions disclosure is where you demonstrate that SECR is informing real decisions, not just generating numbers. Lighting upgrades, controls work, behavioural campaigns, fleet electrification: capture them as they happen, not weeks after the year ends.
Make SECR Reporting Work Harder For You
SECR reporting is a regulatory minimum, but the data behind it should drive real decisions on energy cost, carbon performance and capital planning. Companies that treat it as a tick-box exercise miss the value. Companies that build it into their operating rhythm get cleaner data, faster audits, and a credible foundation for SBTi, CSRD and net zero work later.
We help UK companies build SECR reporting processes that hold up to scrutiny and translate into action. If you are approaching a financial year end, or last year’s submission felt harder than it should have, get in touch at www.gtconsulting.co.uk.